One reason for concern is that the SEC gives little attention to life insurers in the proposal, does nothing to assess the impact of the proposal on life insurers, and relies on reports, such as a broker-dealer study from RAND, that see little about life insurers, Wilkerson writes.

The SEC proposal for a form related to the best interest proposal “is built on a template of full a full-service broker-dealer and fits limited purpose broker-dealers or investment advisers affiliated with life insurers poorly,” Wilkerson writes.

Wilkerson gives non-cash agent compensation as an example of a life insurance tradition that needs extra attention.

Life insurers have used production credits to reward agents with plaques, extra educational opportunities, tech support and marketing assistance for decades, Wilkerson writes.

That kind of compensation is already highly regulated, and it helps insurers and insurance distributors train and motivate agents, Wilkerson writes.

Any new regulations “should not burden or preclude the operation of compensation arrangements and business models, including non-cash compensation arrangements, such as producer meetings that are educational or that reward production,” Wilkerson writes.

The would much rather see new compensation disclosure requirements than limits on how insurers operate, Wilkerson writes.

Wilkerson also notes that life and annuity buyers already get many disclosures, that regulators should be conscious of the possibility of consumer disclosure overload.